The facts of this matter are uncontested. Petitioners James Sheils, William Gregory and George Gregory were partners in a stock brokerage firm during the tax years in question. The partnership sustained heavy business losses in 1969. Thereafter, the partnership members and their wives filed amended returns applying for Federal and New York State tax refunds for 1967 and, except for petitioners George and Mary Gregory, who did not apply for a Federal refund in 1968, 1968 as...
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